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1 3 February 2015

2 EMA/CHMP/QWP/245074/2015
3 Committee for Human Medicinal Products (CHMP)

4 Guideline on manufacture of the finished dosage form


5 Draft

Draft agreed by QWP, BWP February 2015

Adopted by CHMP for release for consultation 23 April 2015

Start of public consultation 09 July 2015

End of consultation (deadline for comments) 09 January 2016

Agreed by QWP, BWP <Month YYYY>

Adopted by CHMP <DD Month YYYY>

Date for coming into effect <DD Month YYYY>

7
8 This guideline replaces the Note for Guidance on Manufacture of the Finished Dosage Form
9 (CPMP/QWP/486/95)

Comments should be provided using this template. The completed comments form should be sent
to QWP@ema.europa.eu

10
Keywords Manufacture, drug product

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European Medicines Agency, 2015. Reproduction is authorised provided the source is acknowledged.
11 Guideline on manufacture of the finished dosage form
12 Table of contents
13

14 Executive summary ..................................................................................... 3


15 1. Introduction (background) ...................................................................... 3
16 2. Scope....................................................................................................... 3
17 3. Legal basis .............................................................................................. 3
18 4. Manufacture ............................................................................................ 4
19 4.1. Manufacturer(s) ................................................................................................... 4
20 4.2. Batch Formula ..................................................................................................... 4
21 4.3. Description of Manufacturing Process and Process Controls ........................................ 5
22 4.4. Controls of Critical Steps and Intermediates ............................................................ 7
23 4.5. Process Validation and/or Evaluation....................................................................... 8

24 Definitions ................................................................................................... 9
25 References ................................................................................................ 10
26 Annex ........................................................................................................ 11

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27 Executive summary

28 This guideline replaces the note for guidance on the manufacture of the finished dosage form
29 (CPMP/QWP/486/95). The note for guidance has been updated to reflect changes to the format and
30 content of the Common Technical Document (CTD) Module 3 dossier. It also addresses current
31 manufacturing practices in terms of complex supply chains and worldwide manufacture. In addition,
32 the content and principles of the ICH Q8 guideline (ref 1) is also taken into account.

33 This guideline does not introduce new requirements on authorised medicinal products for human use.
34 However as stated in article 23 of Directive 2001/83/EC (ref 2) after an authorisation has been issued,
35 the authorisation holder must, in respect of the methods of manufacture and control take account of
36 scientific and technical progress and introduce any changes that may be required to enable the
37 medicinal product to be manufactured and checked by means of generally accepted scientific methods.

38 1. Introduction (background)

39 The objective of the guideline on the manufacture of the finished dosage form is to provide clarification
40 on the type and level of information that should be included in the CTD Module 3 of the marketing
41 authorisation application (MAA) dossier with respect to the manufacturing process description. This
42 description should include information about critical steps and intermediates and provides a link
43 between the pharmaceutical development, the proposed control strategy and process validation. The
44 guideline also addresses aspects related to increased outsourcing and new manufacturing practices
45 such as complex manufacturing chains or issues with prolonged holding times and transportation
46 conditions. Detailed information about requirements of sterilisation processes is provided in a separate
47 guideline.

48 2. Scope

49 This guideline is applicable to the manufacture of the finished dosage form of chemical and herbal
50 medicinal products for human use intended for marketing authorisation. It also applies to variations for
51 authorised products in cases where changes to the manufacturing process affecting the MA are
52 proposed.

53 The principles described are in general also applicable to biological medicinal products. Due to the
54 nature of advanced therapy medicinal products (ATMPs), the guideline is not applicable to these.

55 This guideline does generally not apply to radiopharmaceuticals; however, the principles of this
56 guideline may be applied where relevant.

57 Application of this guideline to the manufacture of investigational medicinal products is not intended,
58 but the principles of this guideline may be applied.

59 3. Legal basis

60 This guideline should be read in conjunction with Directive 2001/83/EC Article 8.3 (d) (ref 2) where it
61 is stated that the application for a marketing authorisation shall contain a description of the
62 manufacturing method.

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63 The requirements on the description of the manufacturing method in the CTD Module 3 of marketing
64 authorisation dossier are described in Annex 1, Part 1 (section 3.2.2.3) to this Directive and will be
65 further elaborated in this guideline.

66 4. Manufacture

67 The headings of this guideline follow the structure of the CTD format Module 3, Section 3.2.P.3
68 Manufacture.

69 Only product specific aspects of manufacture need to be described and included in the MA-dossier;
70 general elements of Good Manufacturing Practice (GMP), (ref 3) should not be included.

71 4.1. Manufacturer(s)

72 For each stage of the manufacturing process (including the assembly and testing), details should be
73 given of all the individual sites involved (including those from the same company). The name, address
74 and responsibility of each manufacturer, including contractors should be provided.

75 The company responsible for the final release of the product onto the market shall be specified. Only
76 those sites that are involved in the manufacture and control of finished product until release need to be
77 included.

78 4.2. Batch Formula


79 The batch formula for the intended batch size should be stated. In case a range of batch sizes is
80 proposed, the batch formula should be provided for at least the highest and lowest batch sizes.

81 An application for a range of batch sizes should be adequately justified taking into account the
82 guidance provided in the guideline on process validation (ref 4).

83 If the bulk product is assembled into different presentations or packs, the production batch size should
84 be defined by the original bulk before any division. When the length of the subsequent processes and
85 assembly is considered critical (e.g. filling for aseptically manufactured products), the division pattern
86 should be indicated.

87 The batch size for a product to be marketed should normally be compatible with qualified industrial
88 equipment. It should be sufficient enough to allow process capability to be established. For example, a
89 commercial batch size for solid oral dosage forms should be at least 100,000 units unless justification
90 is provided (e.g. orphan drugs).

91 If sub-batches are prepared and combined for subsequent processing, their formulae and the number
92 of sub-batches per intended batch size should be stated. In addition, if a batch is sub-divided towards
93 the end of the process to reflect equipment processing capability, this should be clearly indicated. The
94 number of sub-batches per intended batch size should be justified.

95 In case of continuous manufacture, the information about batch size in traditional terms might not be
96 relevant; however information how a batch is defined should be provided. The expected size of one
97 campaign (e.g. period of time) should be stated.

98 The names, quantities and reference to the quality standards of all ingredients used in the course of
99 the manufacture should be stated. This includes ingredients which are removed from the product
100 during the production process, such as granulation liquids, solvents and gases.

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101 Ingredients that may not always be used should also be mentioned, such as acids and alkalis for pH
102 adjustment. Overages must be clearly indicated in quantitative terms and justified in the
103 pharmaceutical development section of the dossier.

104 In justified cases, upper and lower acceptance limits for the actual quantity of each ingredient could be
105 stated.

106 When the quantity of an active ingredient to be used is calculated from the actual assay value of the
107 batch of that active ingredient ("factorisation"), this should be stated and justified. If another
108 ingredient is used to keep the total mass per batch equal to the quantity provided for in the batch
109 manufacturing formula, this should also be indicated.

110 4.3. Description of Manufacturing Process and Process Controls

111 General aspects

112 A narrative description of the full manufacturing process should be provided, accompanied by a flow
113 chart describing each step of the process with respective in-process controls where relevant and
114 showing at each stage where materials enter the process. In case a Design Space is proposed, this
115 should be presented in a transparent manner.

116 It is important that the process descriptions are comprehensive, suitably detailed and describe process
117 steps in a sequential manner including batch size(s) and equipment type(s) and size(s) where
118 appropriate. In case of continuous manufacturing, the description of manufacturing process is expected
119 to be provided in the same way. Emphasis should be given on frequency of in-process controls and it
120 should be clearly stated when the release testing is performed.

121 The manufacturing process description should be adequately justified by development, in particular
122 any process operating conditions or ranges. In addition, and where relevant, any required
123 environmental conditions during manufacture should be stated e.g. low humidity for an effervescent
124 tablet.

125 The steps and points at which process controls, intermediate tests or final product controls are
126 conducted should be identified. To make the process fully understandable and to allow assessment of
127 the validity of the process validation studies/ validation protocol to support the claimed manufacturing
128 process, all steps in the process should have the necessary detail in terms of appropriate process
129 parameters along with their target values or ranges.

130 The description of a manufacturing process with wide acceptance ranges (or described only by an
131 upper or lower limit), generally requires a more thorough discussion and/or scientific rationale in the
132 manufacturing process development section.

133 In some more complex cases (e.g. biotech products, use of models for process control, continuous
134 manufacturing processes), information of how accidental deviations from the approved manufacturing
135 process will be managed can be helpful to assure that the intended quality of the product is retained.

136 Full scale manufacturing process validation is not requested at the time of application for certain types
137 of products (ref 4). If the result of such full scale study is not available at the time of submission, it is
138 expected that process parameters' settings identified during manufacturing process development are
139 laid down in the process description. In the event that any changes are required to the registered
140 process parameters as a result of full scale process validation studies, then these changes should be
141 sought post approval by way of variation, in accordance with the variation Regulation (ref 5, 6).

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142 Every drug product manufacturing process (including manufacturing durations, hold times and
143 conditions during transport) has an associated control strategy. The control strategy should be outlined
144 based on development studies. Consideration should be given to what extent the assurance of quality
145 is founded on the manufacturing process itself. The significance of the process description and process
146 controls as part of the overall control strategy should be evaluated. It is expected that different control
147 strategies may be utilised in case real time release testing (RTRT) (ref 7) is proposed, a design space
148 is claimed (ref 1) or a standard manufacture is performed. Possible elements of the control strategy
149 are described in the glossary of ICH Q8 (ref 1) and Q10 (ref 8).

150 Expected level of detail in the manufacturing process description

151 Though it is expected that process description is considered in relation to other elements of the control
152 strategy (ref 1), there is a need to describe the manufacturing process in relevant detail since
153 consistent quality of a product cannot be safeguarded by end product testing.

154 The same requirements apply to the level of detail in the manufacturing process description
155 irrespective of the development approach, i.e. if the product has been developed by the traditional or
156 enhanced approach (ref 1).

157 The operating principle for the equipment used should be described for each unit operation. The type
158 of equipment should generally be stated (general reference to suitable equipment is not acceptable).
159 The critical steps and points at which process controls, intermediate testing or final product controls
160 are conducted should be clearly identified. Steps in the process should have the necessary detail in
161 terms of appropriate process parameters along with their target values or ranges (general reference to
162 typically set points is not acceptable). The process parameters included in the manufacturing process
163 description should not be restricted to the critical ones; all parameters that have been demonstrated
164 during development as needing to be controlled or monitored during each unit operation, to ensure
165 that the output from a processing step and also that the final product is ultimately of the intended
166 quality need to be described. Details of non-critical process parameters should also be included at an
167 appropriate level of detail to at least give a standard/basic description of relevant steps.

168 An example of what type of details should be included in the manufacturing description is presented in
169 the annex.

170 Technical adaptations in the manufacturing process

171 It would generally be expected that regardless of the number of finished product manufacturing sites
172 proposed, essentially the same manufacturing process would be followed for a specific medicinal
173 product. However, some technical adaptations might be necessary, if more than one manufacturer or
174 manufacturing site for the drug product is foreseen. Depending upon equipment availability, different
175 pieces of equipment could be used for the same manufacturing processing step. The following
176 examples illustrate the possible use of technical adaptations for different manufacturing processing
177 steps.

178 Solid oral dosage forms

179 Different equipment can be used for:

180 Wet granulation (wet granulation by high shear -, low shear - or fluid bed granulation);

181 Granule drying (e.g. fluid bed-, tray drying, one pot (high shear granulation/drying) systems);

182 Dry granulation (roller compaction or slugging);

183 Sizing/delumping (e.g. oscillating -, rotating - or hammer mill);

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184 Coating (e.g. pan coating, fluidized bed coating);

185 Dry blending (e.g. high shear blender, IBC blender, conical screw blender, V blender); and

186 Tablet compression on a fully instrumented or manually controlled tablet press.

187 Liquid dosage forms

188 Preparation of solutions can be performed in simple stainless steel tanks equipped with a stirrer and/or
189 homogeniser or in advanced mixing/homogenising equipment which can be run under vacuum.

190 Where technical adaptations are proposed in the manufacturing process, the use of such adaptations
191 should be fully justified and supported by evidence, showing that all steps proposed will consistently
192 produce any intermediate and finished product that comply with the in process controls and the
193 product specifications. Irrespective of differences in the manufacturing process, the final drug product
194 should be characterised by one release and one shelf-life specification.

195 Where relevant, the justified technical adaptations in various manufacturing steps in the manufacturing
196 process of one or more manufacturers and corresponding in-process controls should also be
197 transparently shown in separate flow-charts, which, if applicable, should also include all adaptations.
198 On presentation of separate flow-charts in a dossier the different manufacturing steps should be listed
199 and the adaptations should be compared to each other by the applicant. The applicant should justify
200 that adaptation, on the basis of using different equipment, do not have any significant influence on the
201 drug product quality and this should be supported by data. The in-process controls and corresponding
202 acceptance limits should also be described, when relevant. Where any differences are proposed at
203 different manufacturing sites, the information should always be presented in the same module 3
204 section document, but if required differentiated based upon the actual manufacturing site.

205 In contrast to technical adaptations as described above, truly alternative manufacturing processes,
206 which use different principles and may or may not lead to differences in the in-process control and/or
207 drug product quality are not acceptable (e.g. using different sterilisation procedures terminal
208 sterilisation of end product vs. aseptic manufacture using sterile filtration possibly to reflect the use
209 of different containers with different heat resistance properties; wet granulation vs. dry granulation).

210 4.4. Controls of Critical Steps and Intermediates

211 All critical steps and intermediates isolated during the manufacture of the finished drug product should
212 be listed in this section including details about the sampling strategy, applied test methods and
213 acceptance criteria. The fact that a process parameter is controlled and verified to be within a range
214 that does not affect a critical quality attribute (CQA) does not make it non-critical by default. While the
215 risk is reduced the monitoring with its established acceptance criteria should be included in the
216 description to assure a sufficient regulatory oversight. The justification for the identification of steps as
217 critical or non-critical should be provided including link to experimental data in pharmaceutical
218 development (e.g. risk assessment table) if applicable.

219 Bulk storage

220 A manufacturing process generally involves a series of sequential processing steps, where the output
221 from one step is isolated before it is incorporated into the next processing step, possibly after some
222 confirmatory testing of quality. Any isolated material can therefore be considered as bulk and
223 depending upon the dosage form and proposed manufacturing facilities and arrangements, the bulk
224 (multiple bulks possible in a single process) may be stored and as necessary transported in a suitable

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225 container before further processing. Therefore, bulk storage is any stage in the manufacturing process
226 of any pharmaceutical product where bulk is held in storage prior to further processing e.g. bulk
227 solution prior to filling, granulates, uncoated tablets etc.

228 It should be stated whether any bulk product is to be stored and if so, under which conditions. The
229 maximum holding times of bulk product should be stated and appropriately supported by data (e.g.
230 challenging the maximum hold time in process validation studies or by providing dedicated stability
231 studies for the bulk storage). In addition, where relevant, the maximum processing times of both
232 individual and a combination of processing steps (e.g. from the start of manufacture to packaging for
233 aseptic processing) should be appropriately supported. The reasons for any prolonged
234 storage/processing times should be stated and be consistent with GMP. Although not defined
235 anywhere, as a general rule, prolonged storage means more than 30 days for solid oral dosage forms
236 and more than 24 hours for sterile products.

237 Where relevant, stability data to support the holding time should be provided (on at least two pilot
238 scale batches). The stability studies should be performed at relevant temperature and humidity with
239 regards to the expected bulk storage conditions (if relevant temperature and humidity during storage
240 does not correspond with ICH condition, other conditions should be used).

241 In case of bulk storage, the product shelf-life should be calculated according to the Note for Guidance
242 on the start of shelf-life of the finished dosage form (ref 9). If other approaches to calculate shelf life
243 are proposed, these should be declared and justified through inclusion of batches that represent the
244 full proposed holding intervals of the bulk product (intermediate) in the finished product stability
245 program.

246 Transportation of bulk between manufacturing sites should be explained and justified. The principles of
247 the guideline on Good Distribution Practice (ref 10) and guidance given in GMP Annex 15 on transport
248 should be taken into consideration. The impact of short or longer excursions outside of the original
249 storage conditions should be discussed and, where necessary, supported by accelerated stability data.

250 The suitability of the proposed bulk container closure system should be justified. The type and level of
251 information required will depend on the nature of the bulk product. The materials of the bulk container
252 closure system should be described in the dossier and its control specification stated.

253 4.5. Process Validation and/or Evaluation

254 Description, documentation, and results of the validation and/or evaluation studies should be provided
255 in this section. For more details see Process Validation guideline (ref 4).

256

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257 Definitions (ref 1)

258 Control Strategy:

259 A planned set of controls, derived from current product and process understanding that ensures
260 process performance and product quality. The controls can include parameters and attributes related
261 to drug substance and drug product materials and components, facility and equipment operating
262 conditions, in-process controls, finished product specifications, and the associated methods and
263 frequency of monitoring and control.

264 Critical Process Parameter (CPP):

265 A process parameter whose variability has an impact on a critical quality attribute and therefore should
266 be monitored or controlled to ensure the process produces the desired quality.

267 Critical Quality Attribute (CQA):

268 A physical, chemical, biological or microbiological property or characteristic that should be within an
269 appropriate limit, range, or distribution to ensure the desired product quality.

270 Design Space:

271 The multidimensional combination and interaction of input variables (e.g., material attributes) and
272 process parameters that have been demonstrated to provide assurance of quality. Working within the
273 design space is not considered as a change. Movement out of the design space is considered to be a
274 change and would normally initiate a regulatory post approval change process. Design space is
275 proposed by the applicant and is subject to regulatory assessment and approval.

276 Real Time Release Testing:

277 The ability to evaluate and ensure the quality of in-process and/or final product based on process data,
278 which typically include a valid combination of measured material attributes and process controls.

279

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280 References
281 1. ICH Q8 (R2) (Pharmaceutical development), EMA/CHMP/ICH/167068/2004;

282 2. Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the
283 Community code relating to medicinal products for human use;

284 3. Eudralex volume 4 (GMP guidelines);

285 4. Guideline on process validation for finished products - information and data to be provided in
286 regulatory submissions EMA/CHMP/CVMP/QWP/BWP/70278/2012 Rev. 1;

287 5. Commission Regulation (EC) No 1234/2008 concerning the examination of variations to the terms
288 of marketing authorisations for medicinal products for human use and veterinary medicinal
289 products;

290 6. Guidelines on the details of the various categories of variations, on the operation of the procedures
291 laid down in Chapters II, IIa, III and IV of Commission Regulation (EC) No 1234/2008 of 24
292 November 2008 concerning the examination of variations to the terms of marketing authorisations
293 for medicinal products for human use and veterinary medicinal products and on the documentation
294 to be submitted pursuant to those procedures;

295 7. Guideline on Real time release testing EMA/CHMP/QWP/811210/2009-Rev1;

296 8. ICH Q10 (Pharmaceutical quality system). EMA/CHMP/ICH/214732/2007;

297 9. Note for guidance on the start of shelf-life of the finished dosage form CPMP/QWP/072/96 /
298 EMEA/CVMP/453/01;

299 10. Guideline on Good Distribution Practice of medicinal products for human use 2013/C 343/01.

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300 Annex
301 Example of a manufacturing process description: expected level of detail

302 Drug product: 200 mg tablet

303 Process step: wet granulation

304 Operating principle: high shear granulation

305 Equipment type: vertical impeller geometry (bottom driven), 600 L capacity

306

307 Non exhaustive list of process parameters which should be considered:

308 Delumping sieve size.

309 Mixing time for binder solution.

310 Mixing speed for binder solution.

311 Fill volume.

312 Premix time.

313 Premix impeller speed.

314 Premix chopper speed.

315 Binder solution pressure.

316 Binder solution feed pump speed.

317 Binder solution flow rate.

318 Binder solution total amount.

319 Impeller rotation speed for the different granulation phases.

320 Chopper rotation speed for the different granulation phases.

321 Wet massing time.

322 Bowl temperature.

323 Product temperature.

324 Wet mass screen size.

325

326 List of parameters that have been demonstrated during development as needing to be
327 controlled or monitored during the unit operation:

328 Fill volume.

329 Premix time.

330 Binder solution flow rate.

331 Binder solution total amount.

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332 Impeller rotation speed for the different phases.

333 Chopper rotation speed for the different phases.

334 Wet massing time.

335 Wet mass screen size.

336

337 Narrative description:

338 1. Weigh and delump the required amount of drug substance and intra-granular excipients.

339 2. Weigh the required amount of binder excipient and purified water; charge the purified water in a
340 mixing vessel and dissolve the binder excipient; mix until a clear solution is obtained.

341 3. Load Drug substance, intra-granular excipient 1, intra-granular excipient 2 and intra-granular
342 excipient 3 in the bowl of the high shear mixer granulator. Target fill volume: 30% w/v (180 kg).

343 4. Mix the dry material for 2 minutes (target impeller speed: 95 rpm; chopper off).

344 5. Wet the dry mix (from step 4) with the binder solution (from step 2) added by fine atomization
345 through a binary nozzle at a target rate of 9 kg/min for 3 minutes (total amount added: 27 kg
346 (15% w/w); target impeller speed: 95 rpm; chopper off).

347 6. Wet mass the blend for 5 minutes with impeller (target impeller speed: 172 rpm; chopper speed:
348 2000 rpm).

349 7. Screen the wet mass through in-line sizing mill unit of 1 mm and transfer to fluid bed dryer.

350

351 Description of the manufacturing process (traditional application):

352

353

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354

355 Description of the manufacturing process (QbD application):

356

357

358 To note:

359 Same level of detail whatever the type of application (traditional or enhanced pharmaceutical
360 development);

361 Operating principle described;

362 Equipment type / capacity described;

363 Critical and non-critical process parameters described (with target values or ranges) leading to a
364 comprehensive description of the unit operation;

365 Reduced list of process parameters remaining in the description compared to the initial list; the
366 following has been taken into account:

367 Nature of the drug substance (e.g. the drug substance is chemically stable thus no need to
368 describe the environmental and product temperatures);

369 Degree of complexity of the dosage form (e.g. the tablet is highly dosed thus no need to
370 describe in details the pre mixing step);

371 Degree of complexity of the process (e.g. the delumping of raw materials before processing is
372 not an important step thus no need to describe the delumping sieve size; the preparation of
373 the binder solution is a straight forward operation which is merely monitored by the visual
374 control of the final solution thus no need to describe the mixing parameters; the binder
375 solution addition is adequately summarized by the output flow rate thus no need to describe
376 the liquid pressure and the pump speed). Regarding the delumping operation and the binder
377 solution preparation, none of the critical quality attributes (CQAs) of the intermediate product
378 or the final product is dependent on these operations. For this reason also, the description does
379 not include process parameters for these operations.

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